The Fourth Plenary Session of the 20th CPC Central Committee proposed accelerating the establishment of a high-level socialist market economy system and enhancing the driving force for high-quality development. It emphasized the need to “accelerate the improvement of the market-oriented allocation system for production factors,” highlighting the fundamental role of deepening market-oriented reforms of production factors in promoting high-quality development. The Central Economic Work Conference in 2025 further proposed expanding pilot programs for market-oriented reforms of production factors. A series of policy documents and work deployments issued by the Party Central Committee and the State Council signify that China’s construction of a market system for production factors has entered a deeper stage, providing a solid institutional guarantee for building markets for emerging production factors, including data.

Overall, the market system for data elements is taking shape at an accelerated pace. Governance frameworks are gradually improving, participation by market entities is continuously increasing, and preliminary achievements are becoming evident. At the same time, it should be acknowledged that the growth of any emerging market system is accompanied by adjustment and exploration. While actively promoting development, it is necessary to rationally consider potential biases or risks during the construction process and further improve the governance system to ensure that market-oriented reforms of production factors advance in a stable and sustainable manner.

Risks to Guard Against in the Construction of a Data Elements Market

1. First, prevent the “inflation” of concepts. In recent years, explorations around concepts such as “data assetization,” “data tokenization,” and “data certification” have continued to expand, reflecting the vitality of policy innovation. However, if the pace of concept renewal is too fast or if the terminology lacks consistency, it may result in semantic dispersion, implementation deviations, and inconsistent understanding of regulations in practice. If local authorities and institutions conduct independent explorations before a unified standard and clear boundaries are established, it may lead to a situation where “discourse leads while mechanisms lag,” creating risks such as redundant designs and fragmented policies. The enrichment of concepts should be grounded in institutional logic and governance constraints, rather than replacing mechanisms with terminology. Neglecting standard coordination and regulatory constraints and excessively pursuing the quantity or popularity of “new concepts” may cause fluctuations in institutional innovation and affect the stability of market expectations.
2. Second, prevent the risk of stacked technological configurations. With rapid platform development, some projects introduce multiple cutting-edge technologies, such as blockchain, privacy computing, and trusted execution environments, to demonstrate advancement and security. While technological innovation is undoubtedly a key driver of market development, if the actual fit and cost-effectiveness are not fully assessed, it may result in “overemphasis on technology and underemphasis on practical value.” Excessive technological stacking often increases maintenance complexity and management burdens, potentially weakening platform usability and operational efficiency. If technology adoption is detached from scenario-based needs, “demonstrative innovation” may replace “functional innovation,” leading to short project lifecycles and high operating costs. Therefore, it is essential to guard against superficial technological development and ensure that technology serves institutional and market logic.
3. Third, prevent the superficialization of project outcomes. During policy pilots and demonstration initiatives, local authorities often launch “first” or “pilot” projects to create early-stage demonstration effects. Such explorations are useful for accumulating experience and increasing social attention. However, without supporting mechanisms and pathways for commercialization, there is a risk of “projects debuting quickly but transactions struggling to continue.” The focus of constructing a data elements market is to establish sustainable circulation and operational mechanisms, rather than achieving one-time showcase results. If market activities remain at the level of short-term promotion without stable trading habits and institutional consolidation, it is difficult to generate endogenous growth momentum.

Further Improving the Governance System for the Data Elements Market

To address the above potential risks, the construction of a data elements market should advance collaboratively across institutional, technological, and operational dimensions, further improving the governance system to ensure stability of direction and sustainability of the implementation framework.

1. At the institutional level, greater emphasis should be placed on policy standardization and enforceability. At the national level, the standard system for core links such as data ownership confirmation, inclusion in balance sheets, and circulation transactions should be further improved, with clear definitions and applicable scopes for relevant concepts to form a unified policy and regulatory language. A cross-regional standard coordination mechanism should be established to promote institutional recognition and data interoperability across platforms and scenarios, avoiding fragmented local systems and redundant construction. Industry associations and professional organizations can serve as third-party evaluators and coordinators, dynamically monitoring implementation deviations and providing empirical evidence for policy optimization. Through unified standards, strengthened constraints, and improved coordination, institutional innovation can advance steadily under consistent rules.
2. At the technological level, the principles of “moderation, practicality, and sustainability” should be upheld. The construction of the data elements market should be demand-oriented and scenario-driven, promoting deep integration between technology and institutional objectives. Local platforms should scientifically assess the necessity and long-term value of technological choices, avoiding excessive stacking that complicates systems and wastes resources. Projects supported by fiscal funds should especially establish evaluation mechanisms to clarify the functional contribution, usage frequency, and maintenance costs of technologies, ensuring alignment of investment and benefit. Standardized technological interfaces and modular sharing should be promoted to enhance interconnectivity among platforms, forming a cost-effective and reusable technological ecosystem. By emphasizing both technological governance and institutional constraints, a technological system can be established that is secure, trustworthy, and efficient, enabling technology to genuinely support institutional enforceability and market credibility.
3. At the operational level, long-term governance and sustainable operation should be strengthened. The assessment of the data elements market should shift from “construction progress” to “operational performance,” focusing on transaction activity, data update frequency, user engagement, and revenue stability. Fiscal incentives and policy support should be linked to operational quality, providing sustained support to platforms with sound mechanisms and performance, thus encouraging long-term management. For underperforming projects, exit and adjustment mechanisms should be established to optimize resource allocation. Models such as co-construction and co-operation by enterprises or market-oriented mechanisms can enhance platforms’ self-sufficiency and commercial sustainability. Additionally, regulatory evaluation and data security review should be strengthened to ensure market operations are conducted within a legal and compliant framework, forming a positive feedback loop between policy guidance and market mechanisms and facilitating a smooth transition from “project construction” to “institutional normalization.”

Conclusion

Currently, the construction of the data elements market is moving from the exploratory phase to a systematic development stage. Improving the governance system is not only necessary to prevent risks and regulate operations, but also serves as the core support for ensuring efficient market mechanisms. In the future, the unity of market logic, legal logic, and governance logic should be upheld. By strengthening institutional norms, refining technological governance, and enhancing operational coordination, the data elements market can progress from “institutional establishment” to “institutional maturity.” Only by continuously improving governance and enhancing governance effectiveness can the goal of data elements being “confirmable, priceable, tradable, and regulable” be achieved, making it a key force in promoting high-quality development and providing a solid institutional guarantee for the establishment of a high-level socialist market economy.

（Source: Shanghai Observer, January 23, 2026）